In the past, the MLA applied only to payday loans, auto title loans, and tax refund anticipation loans.

MLA, which applies to active duty servicemembers and their dependents, now extends to all credit granted for personal, family, or household purposes that is either subject to a finance charge or payable by a written agreement in more than four installments.

The MLA regulation will, however, continue to exclude residential mortgages and credit extended to finance the purchase of personal property (i.e., vehicles).

The rule becomes effective Oct. 1, but compliance will not be mandatory until Oct. 3, 2016.

There are some silver linings in the new rule, Stritzke said, namely:

• The rule provides for a delay of the effective date for applicable credit card accounts until Oct. 3, 2017, giving credit union professionals more time to prepare for changes on those products; and

• The rule will not apply to current loans, and does not impose obligations to monitor the borrower’s covered status for the life of the loan.

“You don’t have to go backward, you just have to go forward,” she said.

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